Random Thoughts on Compliance

Radical Compliance is going on vacation for most of this week. So until we return, it’s time for another edition of random thoughts on all things related to audit, risk, and compliance, plus whatever else comes to mind. Without further delay… 

I’m still alarmed about that report earlier this year finding that most companies have no dedicated case management system. Unwise! Seamless integration of internal reporting and case management are crucial to modern compliance program success.

Prediction: that idea from assistant attorney general Kenneth Polite for compliance officers to certify the effectiveness of their programs will, like any good turkey, never really get off the ground.

The West should not lift its sanctions against Russia no matter what peace deal may or may not happen with Ukraine. Russia’s invasion of Ukraine is one thing; its belligerence to Western values is another. Our sanctions are meant to contain the latter, and they should remain until Vladimir Putin goes.

Large companies would do well to create risk committees of the board, and then assign oversight of cybersecurity and ESG issues to that group. The audit committee has enough to do already.

Hold up — Simu Liu, the star of Shang-Chi and the Legend of the Ten Rings, used to work at Deloitte and got fired from the job? 

I know, I know: Republicans are preordained to sweeping victories this November. Except, the GOP often overplays its hand and ends up nominating kooks who blow it — so I’m not as convinced of Republican victory this fall as others. 

Another prediction: Elon Musk will not acquire Twitter. What is his actual game here? Who cares; the man is a walking governance disaster and shouldn’t be on any board. 

Of all the regulators out there, the Office of the Comptroller of the Currency might be my favorite. Its enforcement settlements are always richly detailed and make for great reading for compliance professionals.

So many companies complaining about a labor shortage! If only there were some group of people elsewhere in the world, willing to come to the United States to live and work. Isn’t there a word for that? Immig- something or other? 

Chef José Andrés deserves the Nobel Peace Prize, like, last week. 

I hope the Public Company Accounting Oversight Board, now under new leadership, finally revives its enforcement efforts and rulemaking agenda. The PCAOB has been dysfunctional and feckless for far too long. 

The job market for compliance professionals still seems booming to me. Week after week, the Compliance Jobs Report rolls along with several dozen updates. Either you’re all super diligent at updating your LinkedIn profiles, or more hiring is happening. Am I right? Drop me an email and share your thoughts. 

Shame on Disney and its disingenuous outrage over Florida’s Don’t Say Gay bill. The company had plenty of opportunity to exercise influence with Florida Republicans before they passed that law, and didn’t. Commitment to ethical values means acting when you can, not when the bad headlines start piling up.

Of course Clarence Thomas should recuse himself from Jan. 6 cases. Not that he will, because he’s an arrogant, aggrieved, prig; but he should.

So Starbucks is promising new benefits to employees, but excluding those benefits from unionized employees under labor law technicalities. I see what CEO Howard Schultz is trying to do and I generally believe he’s a good leader — but I don’t think this strategy will succeed like he thinks. 

Last month I participated in a webinar hosted by Navex to preview its 2022 Hotline & Incident Management Benchmarking Report. Two findings: Fewer whistleblowers are reporting anonymously, and more are reporting retaliation. That’s a welcome evolution in speak-up culture at the abstract level, but it does have big implications for ethics and compliance programs.

Too many internal audit teams still spend too much time on SOX compliance. Automate those processes and pivot to enterprise risk assessments! 

China’s zero-covid strategy is abyssmally dumb, and Xi Jingping is pursuing it simply because he won’t concede that Western mRNA vaccines perform better than Chinese versions. Whatever price the world economy might pay for his pride, it’s unnecessary. 

Employees watching Severance: “Oh my god this is so horrifying!” Private equity overlords watching Severance: “Huh. So how far off is this technology…” 

For all the angst over the SEC’s proposal that companies disclose their Scope 3 greenhouse gas emissions from the supply chain, more interesting to me is that the SEC is pushing companies to back up all those pretty promises of a net-zero future with real metrics and data. That’s the stuff that’s going to get you a shareholder lawsuit, a deceptive advertising claim, or some other headache.

The Washington Commanders is a terrible name for a football team, but the Commanders are a terrible team and its management is even worse. So I guess the name fits. 

The other day my daughter piped up from the back seat: “I want to listen to Mom’s music because Dad music is too old.” Wow. Talk about saying the quiet part out loud.